AFS-16-6571-E

April 18, 2016

 Exemption No. 5651O

 Regulatory Docket No. FAA-2002-11498

Mike Rhodes

Chief Test Pilot

Air Tractor, Inc.

P.O. Box 485

Olney, TX 76374

Dear Mr. Rhodes:

This letter is to inform you that we have granted in part, your petition to extend and amend 

Exemption No. 5651, as amended. In your March 7, 2016 petition, you also requested an 

amendment that would include an exemption from § 91.313(a) as described in FAA Notice 

8900.295 Pilot Training and/or Certification Events Conducted in Restricted Category 

Aircraft. The amendment, if granted, would allow Air Tractor to operate a restricted category 

civil aircraft for other than the special purpose for which it was certificated, or in an operation 

other than one necessary to accomplish the work activity directly associated with that special 

purpose.

At this time, the FAA is granting a six-month extension of the existing relief, while the 

agency considers the broader issues related to granting relief to Air Tractor’s amendment 

request.

The Basis for Our Decision

By letter dated March 7, 2016, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Air Tractor, Inc. (Air Tractor) for an extension of, and amendment to, Exemption 

No. 5651, as amended. That exemption from § 61.31(a)(1) of Title 14, Code of Federal 

Regulations (14 CFR) allows Air Tractor and pilots of AT-802, AT-802A, AT-1002, or AT1002A airplanes to operate those airplanes without holding a type rating, although the 

maximum gross weight of the airplanes exceeds 12,500 pounds.
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Condition #3 has been slightly revised to require Air Tractor to keep current and maintain 

approval of the training manual required to comply with Condition and Limitation number 2. 

This training manual is already approved by AFS-800 with an expiration date of April 30, 

2016. Air Tractor will be issued a separate extension to their approval letter by AFS-800. 

The extension to the training program will expire concurrently with this exemption. 

In your petition, you indicated that there had been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension and amendment of the exemption 

would not set a precedent, and any delay in acting on this petition would be detrimental to Air 

Tractor.

Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 5651, as 

amended, remains valid with respect to this exemption and is in the public interest. 

Under the authority provided by 49 U.S.C. § 106(f), 40113, and 44701, which the FAA 

Administrator has delegated to me, I grant Air Tractor, Inc. and pilots of Air Tractor Models 

AT-802, AT-802A, AT-1002, and AT-1002A, relief from § 61.31(a)(1) to the extent 

necessary to operate these models without holding a type rating for the airplane, subject to the 

following conditions and limitations.

Conditions and Limitations

1. This exemption applies to pilots operating AT-802, AT-802A, AT-1002, and AT1002A aircraft that hold a restricted category airworthiness certificate.

2. Air Tractor must develop and maintain a training program manual(s) that includes the 

following ground training topics for each applicable make and model of aircraft:

a) Aeronautical knowledge training on aircraft systems, and aircraft performance;

b) Handling characteristics that are unique to the aircraft;

c) A review of the approved airplane flight manual; and

d) A cockpit familiarization checkout.

3. Air Tractor may continue to exercise the privileges of this exemption only if it 

complies with the following:

a) Air Tractor must continue to maintain approval of its training manual, and obtain 

approval for any revisions to the approved training manual, from AFS-800. 

b) The training manual(s) and approval documentation must be made available to 

any representative of the FAA Administrator, upon request.

4. Except as provided in Condition/Limitation No. 5, before a pilot can serve as pilot in 

command (PIC) in the AT-802, AT-802A, AT-1002, or AT-1002A that pilot must 
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have successfully completed the applicable training in accordance with Air Tractor’s 

training program manual described in Condition/Limitation No. 2.

5. Pilots who have logged at least 100 hours of flight time, with at least 10 hours in the 

preceding 12 months, in an AT-502 series airplane need not complete the training 

requirements of Condition No. 4. A record of this flight time must be made available 

by the pilot upon request by a representative of the FAA Administrator.

6. Any person (including Air Tractor) that provides training described by 

Condition/Limitation No. 4 must -

a) Ensure each pilot logs the ground training in his or her logbook, or record such 

training in the pilot’s training record; and

b) Make this record of training available for review to any representative of the FAA 

Administrator, upon request.

7. The person qualified to give training under this exemption must meet the following 

minimum qualifications:

a) Be authorized by Air Tractor to give this instruction;

b) Hold at least a commercial pilot certificate; and

c) Meet the following experience requirements:

i. 500 hours of flight time in turbine-powered agricultural type airplanes; 

or

ii. 1,000 hours of flight time in agricultural type airplanes which includes at least 

100 hours of flight time in an AT-502 or AT-802, or AT-1002, series airplane

8. Air Tractor must make a copy of this exemption available to each pilot who serves as 

PIC in the AT-802, AT-802A, AT-1002, or AT-1002A aircraft.

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 5651, as amended to October 31, 

2016, unless sooner superseded or rescinded. 

 

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service